Code of Supplier Conduct

Eaton's Supplier Code of Conduct helps us to select business partners who follow workplace standards and business practices that are consistent with our company's values. These requirements are applied to every supplier of Eaton Corporation globally.

A. Code of Conduct
1. General Principle: Suppliers' plants shall operate in full compliance with the laws of their respective countries and with all other applicable laws, rules and regulations. 2. Environment: Suppliers' plants must comply with all applicable environmental laws and regulations.
3. Child Labor: Suppliers shall employ only workers who meet the applicable minimum legal age requirement. Suppliers must also comply with all other applicable child labor laws.
4. Forced Labor: Suppliers shall not use any prison, indentured or forced labor.
5. Wages and Hours: Suppliers' plants shall set working hours, wages and overtime pay in compliance with all applicable laws. Workers shall be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater.
6. Discrimination: Suppliers shall employ workers on the basis of their ability to do the job, not on the basis of their personal characteristics or beliefs (including race, color, gender, nationality, religion, age, maternity or marital status).
7. Freedom of Association: Suppliers' workers are free to join associations of their own choosing and have the freedom of collective bargaining where the local law confers such rights.
8. Gift and Gratuity Policy: The offering or acceptance of kickbacks, bribes and other illegal payments subverts the very essence of competition and erodes the moral fiber of those involved. These include gratuities (i.e., anything of value) offered to governmental officials or employees. Such activities are not condoned and will not be tolerated. Also, Eaton prohibits the offer or acceptance of gifts or gratuities that the recipient likely would consider to be of substantial value. Any supplier that violates this item A (8) Gift and Gratuity Policy risks immediate loss of all existing and future Eaton business.

B. Compliance Monitoring
The supplier will allow Eaton Corporation and/or any of its representatives or agents unrestricted access to its facilities and all relevant records at all times, whether or not notice is provided in advance. Eaton will continue to develop monitoring systems to assess and ensure compliance.

C. Application to Subcontractors
This Code also applies to any subcontractor(s) to the supplier, and the supplier is fully responsible for compliance by any such subcontractor(s) as if it were the supplier itself in noncompliance. Eaton reserves the right to approve all subcontractors.

D. Event of Violation
If the supplier does not comply with this Eaton Corporation Global Sourcing Supplier Code of Conduct, Eaton requires that the supplier implement a corrective action plan to cure the noncompliance within a specified time period (furnished by Eaton in writing). If the supplier fails to meet the corrective action plan commitment, Eaton will terminate the business relationship, including suspending placement of future orders and potentially terminating current production. Eaton has the right to hold supplier responsible for any costs of investigating noncompliance. An exception to the application of this item D is a violation of item A (8) Gift and Gratuity Policy, where the penalty is as stated.